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    Double Tax Avoidance Agreement Between India And Japan

    Friday 17th September 2021

    (v) other financial institutions whose capital is wholly owned by the Government of Japan, as may be agreed from time to time between the Governments of the States Parties; Desiring to amend the Agreement between the Government of the Republic of India and the Government of Japan on the Prevention of Double Taxation and the Prevention of Tax Evasion in the Field of Income, as amended by the Protocol signed at Tokyo on 24 February 2006 (hereinafter referred to as “the Agreement”), signed at New Delhi on 7 March 1989, (1) States Parties shall support each other in the recovery of tax claims. This aid shall not be limited by Articles 1 and 2. The competent authorities of the States Parties may, by mutual agreement, regulate the application of this article. The ITAT found that all of the taxable person`s income, including the income of his PE (branch) in Japan, was taxable in India, subject to a credit for taxes paid in Japan, if any. The ITAT considered that the Indian tax authorities` concern about the double benefit of the losses suffered by pe was unfounded, as this possibility could occur: (c) decision. The ITAT found that under Article 5(1) of the ITA, the taxable income of a person resident in India should encompass all income from any source. The tax treaty between India and Japan provides for the exemption from double taxation of income in India, in accordance with Article 23 of the Tax Convention, which provides for a tax credit for taxes paid in Japan in respect of India`s income tax obligation on such income. Therefore, under the tax treaty, the income of PEs in Japan in India was not exempt, but was only a deduction of taxes paid in Japan from that income. The Indian Income Tax Act 1961 (ITA) provides that the taxable income of a person resident in India includes all income from any source (i.e. a resident is taxable worldwide). By referring to that provision of the ITA, the taxable person attempted to compare the loss of the Japanese branch with his taxable income in India. During the tax procedure, the Indian tax authority found that the admission of losses incurred by foreign (Japanese) branches against taxable profits in India would amount to a “double dip” of losses and therefore could not be accepted in the context of international taxation. .

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